Federal

  • March 01, 2024

    House Tax Panel To Prep Members On OECD Pillar 1

    Neither Republicans nor Democrats on the House Ways and Means Committee have opined much about the OECD profit reallocation plan known as Pillar One, but they will gain valuable information during an upcoming subcommittee meeting, a tax staffer for the panel said Friday.

  • March 01, 2024

    Menendez Associate Pleads Guilty In Bribe Case

    A New Jersey insurance broker pled guilty Friday to bribing Sen. Bob Menendez and his wife, Nadine, by buying her a Mercedes-Benz convertible, under an agreement to cooperate with federal prosecutors.

  • March 01, 2024

    Taxation With Representation: Pillsbury, Cleary Gottlieb

    In this week's Taxation with Representation, First Advantage Corp. acquires Sterling Check Corp., International Game Technology spins off two subsidiaries, Disney merges its media operations in India with Reliance Industries, and Atlas Energy Solutions purchases Hi-Crush.

  • March 01, 2024

    IRS Amends Language In Clean Hydrogen Proposal

    The Internal Revenue Service issued a correction notice Friday to change the language of a proposal relating to clean hydrogen production and whether such facilities are treated as energy property.

  • March 01, 2024

    Weekly Internal Revenue Bulletin

    The Internal Revenue Service issued its weekly bulletin Friday, and it included notice of a variety of rate updates.

  • February 29, 2024

    Logger Failed To Report $3M In Foreign Banks, Judge Rules

    A logger failed to report more than $3 million he kept in foreign accounts, then fraudulently transferred the bulk of it to his wife when he learned he was being audited by the IRS, a Colorado federal judge said in upholding $1.7 million in penalties.

  • February 29, 2024

    House Approves Aviation Excise Tax Extensions

    The U.S. House voted Thursday to extend excise taxes funding the Airport and Airway Trust Fund for two months at their current rates, clearing the path for the legislation to be considered by the Senate.

  • February 29, 2024

    Biz Owner's $2.4M FBAR Dispute Paused For Mediation

    The U.S. government and a retired plumbing business owner mutually agreed to a 90-day stay of their $2.4 million tax dispute over foreign bank account reporting while they try to mediate a solution, a Georgia federal judge said Thursday.

  • February 29, 2024

    IRS Funding Cuts Would Raise Deficit $24B, CBO Says

    A congressional agreement to rescind $20 billion in appropriated funding for the Internal Revenue Service this year would add $24 billion to the federal deficit through the next 10 years, according to Congressional Budget Office projections published Thursday.

  • February 29, 2024

    Ga. Man Convicted In $11M PPP Fraud Case Wants New Trial

    An Atlanta man convicted on dozens of charges stemming from an $11 million pandemic loan fraud scheme has asked a Georgia federal judge for a new trial.

  • February 29, 2024

    IRS Amends Treatment Of Public Utility Debt

    The Internal Revenue Service will not define certain public utilities as not recognizing gross income until the public utility receives the proceeds of a debt issued by the qualifying state financing entity, the agency said Thursday.

  • February 29, 2024

    NJ Towns Can't Sue Netflix, Hulu For Fees, 3rd Circ. Says

    Two New Jersey municipalities cannot sue Netflix and Hulu for franchise fees under the state's Cable Television Act, the Third Circuit held Thursday in a precedential opinion, saying the state statute reserves enforcement of the law to the state Board of Public Utilities.

  • February 29, 2024

    IRS Enforcement Push Will Target 125K Wealthy Nonfilers

    The Internal Revenue Service is ramping up enforcement against 125,000 high-income taxpayers who haven't filed returns since 2017 as a part of its ongoing efforts to increase tax compliance, the agency's chief told reporters Thursday.

  • February 29, 2024

    Senate Confirms First Woman To Top IRS Attorney Post

    The U.S. Senate on Thursday confirmed a former director at EY who previously served as associate chief counsel, international, at the Internal Revenue Service to be the agency's chief counsel, making her the first woman to be confirmed for the role.

  • February 29, 2024

    Medtronic Says 3 Years Of Tax Returns Under IRS Audit

    Three years of medical device company Medtronic's federal income tax returns are being audited by the Internal Revenue Service, the company said in a U.S. Securities and Exchange Commission filing.

  • February 29, 2024

    Bankrupt Endo To Pay $465M To Resolve Opioid Claims

    Drugmaker Endo International has agreed to pay as much as $465 million to resolve criminal and civil claims stemming from its sale and marketing of a powerful opioid, and will turn over its assets to a group of secured lenders who will operate the company under a new corporate structure.

  • February 28, 2024

    Crapo Seeks Changes To Child Tax Credit Provisions In Bill

    The top-ranking Republican on the Senate Finance Committee said Wednesday that he cannot support the bipartisan tax bill pending in the Senate as long as a provision that allows taxpayers to receive a refundable child tax credit based on their prior year's earnings is included.

  • February 28, 2024

    Amgen Seeks Dismissal Of Investor Action Over $11B Tax Bill

    Amgen had no obligation to disclose specific amounts of proposed adjustments to its taxes, the company told a New York federal court as it again demanded dismissal of a proposed class action alleging the company hid a $10.7 billion tax bill from investors.

  • February 28, 2024

    Embattled Philly Loan Biz Principals Hit With RICO Charges

    Legal troubles for the principals of Philadelphia's Par Funding cash advance company are mounting as federal prosecutors hit them with a new indictment adding Racketeer Influenced and Corrupt Organizations Act allegations on top of existing charges that the principals bilked investors out of hundreds of millions of dollars and threatened violence against borrowers.

  • February 28, 2024

    COVID Fraud Jury Can't Hear Of Gov't's Loan Error, Feds Say

    A jury shouldn't be shown evidence of the U.S. government's error in approving a Michigan business owner's application for a Paycheck Protection Program loan while he was under indictment, federal prosecutors have argued.

  • February 28, 2024

    Timeline Rule For Assessing Tax Not Retroactive, Court Says

    A former corporate executive who received a $26 million buyout and then rolled the proceeds over to a retirement account incorrectly claimed that an amended statute of limitations exempted him from paying a penalty, the U.S. Tax Court ruled Wednesday.

  • February 28, 2024

    GOP Reps. Press IRS On Backdating Forms In Easement Case

    Two House Republican tax writers pressed the Internal Revenue Service for details on how it would prevent agency employees from inappropriately backdating official tax documents after the agency admitted last year to doing so in a high-profiled suit involving conservation easement penalty forms.

  • February 28, 2024

    Divorced Woman Can Get Spousal Relief, Tax Court Says

    A divorced woman has satisfied the requirements for innocent spousal relief despite an attempt by her ex-husband to refute her claim, the U.S. Tax Court ruled Wednesday.

  • February 28, 2024

    IRS Delays Tax Deadlines After Wash. Wildfires

    Certain taxpayers in Washington state will have extra time to file tax returns and make payments following wildfires last year, the Internal Revenue Service said Wednesday.

  • February 28, 2024

    Court Should Block IRS 'Fishing Expedition,' Company Says

    A company that claims it has been the victim of an Internal Revenue Service "fishing expedition" after being hit with a raft of document requests urged a Georgia federal judge Tuesday to keep alive its bid to quash the summonses, telling the court the government overstepped its bounds in seeking "a wide variety of duplicative, irrelevant, and unrelated information."

Expert Analysis

  • Mallory Ruling Doesn't Undermine NC Sales Tax Holding

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    Contrary to the conclusion reached in a recent Law360 guest article, the U.S. Supreme Court’s recent Mallory ruling shouldn't be read as implicitly repudiating the North Carolina Supreme Court’s sales tax ruling in Quad Graphics v. North Carolina Department of Revenue — the U.S. Supreme Court could have rejected Quad by directly overturning it, says Jonathan Entin at Case Western Reserve.

  • IRS Criminal Probe Spells Uncertainty For Malta Pension Plans

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    The IRS’ recent scrutiny of Malta pension plan arrangements — and its unusual issuance of criminal administrative summonses — confirms that it views many of these plans as illegal tax evasion schemes, and the road ahead will not be smooth and steady for anyone involved, say attorneys at Kostelanetz.

  • IRS Announcement Will Aid Cos. In Buyback Tax Planning

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    Recent IRS transitional guidance regarding current requirements for reporting and payment of the stock repurchase excise tax will help corporate taxpayers make decisions about records retention and establishing reserves for future tax payments, say Xenia Garofalo and Kyle Colonna at Eversheds Sutherland.

  • Mallory Opinion Implicitly Overturned NC Sales Tax Ruling

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    The U.S. Supreme Court recently declined to review Quad Graphics v. North Carolina Department of Revenue, but importantly kicked the legs from under Quad's outcome a week later, stating in its Mallory decision that the high court has the prerogative to overrule its own decisions, says Richard Pomp at the University of Connecticut.

  • How NIL Collectives Could Be Tax-Exempt After IRS Curveball

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    Since the Internal Revenue Service recently announced that numerous collectives creating paid name, image and likeness deals for collegiate student-athletes do not qualify for tax exemption, for-profit entities and alternative collective structures with incidental student-athlete benefits may be considered to fund NIL ventures, says David Kaufman at Thompson Coburn.

  • Is This Pastime A Side-Gig? Or Is It A Hobby?

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    The recent U.S. Tax Court decision in Sherman v. Commissioner offers important reminders for taxpayers about the documentation and business practices needed to successfully argue that expenses can be deducted as losses from nonhobby income, says Bryan Camp at Texas Tech.

  • Recent Provider Relief Fund Audits Are Just The Beginning

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    Though the Health Resources and Services Administration's initial audits of the Provider Relief Fund program appear to be limited in scope, fund recipients should prepare for additional oversight, scrutiny and disallowances as the HRSA ramps up its efforts, say Brian Lee and Christopher Frisina at Alston & Bird.

  • Flawed Analysis Supports Common Law Tax Deficiency Ruling

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    The Colorado federal district court’s recent decision in Liberty Global, holding that the U.S. Department of Justice may assert a common law tax claim without the notice of tax deficiency required by the Internal Revenue Code, relies on a contorted reading of the statute and irrelevant case law, say Loren Opper and Christie Galinski at Miller Canfield.

  • Review Of Repatriation Tax Sets Justices On Slippery Slope

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    The U.S. Supreme Court’s recent decision to review the constitutionality of the repatriation tax in Moore v. U.S. has implications for many tax rules involving unrealized amounts and could leave the court on the brink of invalidating large swaths of the Internal Revenue Code, say attorneys at Eversheds Sutherland.

  • IRS Guidance Powers Up Energy Tax Credit Transfers

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    Recent IRS guidance on the monetization of energy tax credits provides sufficient clarity for parties to start negotiating transfer agreements, but it is unclear when the registration process required for credits to change hands will be up and running, say attorneys at Shearman.

  • Using Agreements To Cover Gaps In Hydrogen Storage Regs

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    The Inflation Reduction Act's incentives for energy storage have spurred investment in hydrogen storage and production, but given the lack of comprehensive regulations surrounding the sector, developers should carefully craft project and financing agreements to mitigate uncertainties, say Omar Samji and Sarah George at Weil, and attorney Manushi Desai.

  • Secure 2.0 Takeaways From DOL's 2024 Budget Proposal

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    The U.S. Department of Labor’s fiscal year 2024 budget proposal provides insight into the most pressing Secure 2.0 implementation issues, including establishment of a search database for finding lost retirement savings and developing guidance on the execution of newly authorized emergency savings accounts, say attorneys at Maynard Nexsen.

  • Avoiding Negative Tax Consequences In Loan Modifications

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    Borrowers who may be caught in the dramatic uptick in nonperforming commercial real estate loans should consider strategies to avoid income and capital gains tax that may be triggered by loan modifications, says Aman Badyal at Glaser Weil.

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